Legal Opinion

White v. Commissioner

United States Tax Court

Decided August 5, 1997No. Docket No. 20635-96PublishedCited by 15 opinions

Ps submitted requests for abatement of interest to the IRS, which were denied prior to July 30, 1996, the date of enactment of sec. 6404(g), I.R.C. Ps now seek review of the failure to abate interest pursuant to sec. 6404(g). Held: We lack jurisdiction to review the denial of Ps' requests for abatement of interest.

1Opinion of the Court

OPINION

Cohen, Chief Judge:

This case is before us on respondent’s motion to dismiss for lack of jurisdiction. The issue is whether the Court has jurisdiction pursuant to section 6404(g) to review respondent’s determination denying petitioners’ claims for abatement of interest. The resolution of this issue turns on the effective date of section 6404(g). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the time the petition was filed.

Background

Petitioners are husband and wife who resided in Wenatchee, Washington, at the time the petition was filed.

F…

2Cases cited2 opinions

  1. Breman v. CommissionerUnited States Tax Court · 1976
  2. Banat v. CommissionerUnited States Tax Court · 1997

3Cited by15 opinions

  1. Marjorie Cathey Miller v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002
  2. Bourekis v. Comm'rUnited States Tax Court · 1998
  3. Gati v. CommissionerUnited States Tax Court · 1999
  4. Yuen v. CommissionerUnited States Tax Court · 1999
  5. Banat v. CommissionerUnited States Tax Court · 1997

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